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Graham has worked in the Home Office and Department for Constitutional Affairs, where from 1993 until 2004 he worked on DP policy. While developing UK DP policy, he was a member of the UK team that negotiated the EC DP Directive, and led the team of officials that prepared the UK's Data Protection Act 1998. He has represented the UK on the Committee set up under Article 31 of the Data Protection Directive to deal with issues relating to the transfer of personal data to third countries. He was also the UK representative (and intermittent Deputy Chairman) of the Council of Europe's Project Group on Data Protection and Consultative Committee on Data Protection. Through the Council of Europe Graham has helped with the development of data protection laws in a number of countries in central and eastern Europe.